OPINION
BIVINS, Judge.
Each of these cases involves the common appellate issue of whether a conviction resulting from a plea of nolo contendere may be used to enhance a sentence of an habitual criminal pursuant to NMSA 1978, Section 31-18-17 (Cum.Supp. 1986). On defendants' motion, we consolidated the cases. Defendant Marquez raises an additional issue, pursuant to State v. Franklin,
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